August 3, 2021

Volume XI, Number 215

Gary O. Cohen

Gary Cohen practices in the area of federal securities law, focusing on SEC regulation of investment companies and their investment advisers, distributors, and other service providers. He has extensive experience in matters regarding mutual funds, including the representation of independent directors and trustees.

Gary also has extensive experience in SEC regulation of variable annuities and variable life insurance and the life insurance company separate accounts that fund them. He was an official of the Securities and Exchange Commission (SEC) when the U.S. Supreme Court held that variable annuities were subject to SEC jurisdiction, and he participated in the development of the SEC’s regulatory regime. In private practice, he represented the life insurance industry in lengthy proceedings that led to the SEC’s adoption of exemptive rules for variable life insurance, and he prepared the first several registration statements that the SEC declared effective for variable life insurance. The National Association for Variable Annuities has hailed Gary as one of the “recognized experts who helped to build this industry.”

Gary has spoken at, and published papers for, more than 90 legal programs, including the ICI-FBA Conference on Mutual Funds and Investment Management Conference, the PLI Investment Management Institute, and the ALI-ABA Conference on Life Insurance Company Products. He has spoken at SEC staff continuing education sessions and served as a guest lecturer at the Georgetown University Law Center. He has published more than 20 law review and legal periodical articles and has testified more than once in federal court as an expert witness.

Gary worked for five years at the SEC in Washington, D.C., where he served as assistant chief counsel of the Division of Investment Management, the division that regulates investment companies, investment advisers, and life insurance companies separate accounts.


Articles in the National Law Review database by Gary O. Cohen